On behalf of the Greater…

On behalf of the Greater Sudbury Food Policy Council (GSFPC), thank you for receiving our comments on the proposed draft Forest Sector Strategy (ERO: 019-0880).

Please do not implement Ontario’s Forest Sector Strategy and enabling proposals as presented.

On December 4, 2019, the government posted Ontario’s Forest Sector Strategy draft (the Strategy), on the Environmental Registry of Ontario — a detail-free document that claims to reduce “red tape”, create “prosperity” and signal that “Ontario is open for business”. Without waiting to receive all of the public comments on this proposal before making decisions, MNRF posted five additional proposals on the Friday before the holidays. These include proposed permanent exemptions for the industry from both the Endangered Species Act and the Environmental Assessment Act, changes to independent forest audits, forest management planning, and pest management.

Together these additional proposals begin implementing the vision laid out in the Strategy, while the Strategy itself is supposedly still undergoing public consultation. Overall, this fragmented style of releasing documents with minimal substantive content suggests a disingenuous mode of consultation with the public and abrogation of authentic outreach prior to decision making, as is required by the Environmental Bill of Rights, 1993.

Of concern to the GSFPC is the notion that 15 million cubic metres of wood is not being utilized and could be available for expansion into new markets without outlining robust evidence for this case. Located in a northern community, the GSFPC would like the Strategy to make public where this unutilized wood is located within the province and the method to be used for logging of this proclaimed untapped resource, so that the effects to the non-timber forest values of the newly logged area and surrounding forest can be understood and catalogued.

Also of concern is the action to amend the Crown Forest Sustainability Act (CFSA) under the false premise that this statute is duplicative with the Endangered Species Act (ESA). The purposes of the two statutes are different, with the CFSA devoted to sustainable forest management, while the ESA was designed to prioritize considerations for species at risk. This means that while the CFSA seeks to mitigate impacts on species at risk during timber extraction activities (i.e. making them less bad than they otherwise would be), the target of the ESA is recovery of species at risk and their habitat (i.e. improving their status and condition of their habitats).

It strikes us as an overall irresponsible course of action during a time of climate and biodiversity crises and counter to sustainability. The City of Greater Sudbury is home to over 330 lakes and swaths of forests within the region. Many within our community obtain food from our forests and lakes, including plants, berries, fungi, fish and other animals. This can form an important component of ones diet, be an expression of cultural identity and traditions, and a way to connect with out northern landscape. The ability to access these important forest and freshwater resources is dependant on a healthy and sustainable forest landscape. Implementing the Strategy in its current form could have detrimental effects on the forest and freshwater foods that are harvested in our region, and will impact food access, cultural expression, and economic activity.

Please do not go ahead with the draft Strategy or its enabling proposals as planned. Please have meaningful consultation opportunities with the public similar to what you offered select forest companies.

Sincerely,

Greater Sudbury Food Policy Council
www.sudburyfoodpolicy.ca